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ARTICLE · 28 DECEMBER 2022

AED: AML/CFT Supervision Of Non-regulated AIFs

ELVINGER HOSS PRUSSEN, société anonyme
Explore more from ELVINGER HOSS PRUSSEN, société anonyme

The Administration de l'enregistrement, des domaines et de la TVA ("AED") has recently published on its website a new section dedicated to AML/CFT supervision of ...

LuxembourgGovernment, Public Sector
Elvinger Hoss Prussen
Elvinger Hoss Prussen

The Administration de l'enregistrement, des domaines et de la TVA ("AED") has recently published on its website a new section dedicated to AML/CFT supervision of non-regulated Alternative Investment Funds ("AIFs"), excluding Reserved Alternative Investment Funds ("RAIFs")1 . In this context, the AED has notably published the following:

  • an FAQ regarding the RR and the RC

This FAQ is similar to the one previously published by the AED for RAIFs and imposes the appointment of both an RR2 and an RC3 for all AIFs.

  • a RR/RC identification form

This form is similar to the RR/RC identification form previously issued by the AED for RAIFs.

This implies that the AIFs shall have appointed their RC and RR through a decision made at the level of its managerial body (board of the GP, board of managers, board of directors) and defined an AML/KYC framework in accordance with the Law of 12 November 2004 on the fight against money laundering and terrorist financing,

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